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AMA Releases Coding Advice Related to COVID-19

  The AMA has created a quick reference flow chart for CPT reporting for COVID-19 testing that outlines coding options for testing patients for COVID-19. Although testing is not likely to be ordered by pain medicine practices, the flow chart summarizes the coding options for telemedicine, telephone and “virtual check-in” visits. Most of these options were explained in a previous article.

Physicians have contacted AAPM with concerns for caring for patients who are high-risk and do not have internet capabilities or skills. Medicare does not cover the codes for telephone services. However, Medicare pays for “virtual check-ins” (brief communication technology-based service) for patients to communicate with their doctors and avoid unnecessary trips to the doctor’s office. These virtual check-ins are for patients with an established (or existing) relationship with a physician where the communication is not related to a medical visit within the previous 7 days, and does not lead to a medical visit within the next 24 hours (or soonest appointment available and involves 5-10 minutes of medical discussion. The service is reported using HCPCS code G2012.

Patients must verbally consent to receive virtual check-in services; however, you can advise patients of the availability of the service. Medicare coinsurance and deductible apply to these services. The national average reimbursement for code G2012 is about $15.

A new page on the AMA website address CMS payment policies & regulatory flexibilities during COVID-19 emergency.

Providing and Reporting Medicare Telehealth Services During the COVID-19 Outbreak

The Centers for Medicare & Medicaid Services (CMS) has temporarily lifted restrictions on the use of telehealth services to allow beneficiaries to receive care without going to their physician’s office. CMS announced penalties will not be imposed on physicians using telehealth in the event of noncompliance with regulatory requirements under the Health Insurance Portability and Accountability Act. Other telehealth requirements such as patient location and the use of secure communication equipment are also lifted. These relaxed guidelines also apply to patients receiving care for conditions not related to COVID-19.

CMS indicated physicians who want to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing service that is available to communicate with patients. CMS specifically stated that physicians may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype to provide telehealth. Physicians should not use Facebook Live, Twitch, TikTok or other public facing communication services.

The CPT codes used to report telehealth services are the same as if the service was provided in your office. In most instances, this would be an Evaluation and Management Service (CPT 99201-99215). Likewise, the ICD-10 codes reported should be the primary reason for the patient encounter along with any other relevant diagnosis(es). The place of service code (POS) for telehealth (02) should be reported.

Medicare also covers online digital E/M Services (CPT codes 99421, 99422 and 99423) and corresponding codes G2061, G2062, G2063 when the service is provided by qualified non-physician health care professionals.CPT codes for telephone services (99441,99442,99443) are not covered by Medicare but may be covered by some commercial or managed care payers. The CPT guidelines for reporting on-line and telephone services should be reviewed prior to reporting.

It is not known if commercial or managed care payers will follow the CMS guidance on telehealth services. Therefore, you should check with other payers to determine their guidelines before reporting any form of telehealth or non-face-to face service.

Additional information on reporting telehealth services during the COVID-19 outbreak can be found at the following links:

Incorrect Billing of HCPCS L8679 – Implantable Neurostimulator

CMS has issued a MLN (Medicare Learning Network) article concerning the inappropriate reporting of HCPCS supply code L8679 (Implantable neurostimulator, pulse generator, any type) for electro-acupuncture devices. These devices are applied behind the ear using an adhesive and/or with needles inserted into the patient’s ear and do not require surgical implantation.  

Code L8679 should only be reported with procedures that require surgical implantation into the central nervous system or targeted peripheral nerve. These procedures are usually performed in an operating room. The MLN article (number SE2001) provides a list of appropriate procedures that must accompany any claims that include code L8679. It can be accessed here.

As of March 1, 2020, claims billed with HCPCS L8679 must be billed with the same date of service as the applicable surgical procedure code. Claims for code L8679 reported with an appropriate surgical code will be suspended for medical review to verify that coverage, coding, and billing rules have been met. Claims submitted without an appropriate procedure code will be rejected.

Please make sure your coding and billing staff are aware of the correct use of code L8679 and the changes in the CMS policy. The National Coverage Determination Manual Section 160.7 on implanted peripheral nerve stimulators is available here.

Upcoming RUC Survey

In the next few weeks we will be contacting a random selection of members to participate in an important AMA/Specialty Society Relative Value Scale Update Committee (RUC) survey of physician work for codes 64633-64636 which describe destruction of facet joints. The Medicare payment schedule is based on physician work, practice expense and professional liability insurance. Our specialty needs your help to assure relative values will be accurately and fairly presented to the Centers for Medicare and Medicaid.  

AAPM is conducting this survey for the RUC in partnership with several other medical specialties including the American Academy of Physical Medicine and Rehabilitation, American Society of Anesthesiologists, and the Spine Intervention Society. If you are a member of one or more of these additional societies, you may see a survey request from them (rather than from AAPM). In such instance, we ask that you treat their request as similarly vital. We will compile all relevant survey data from the partnering societies for our presentation to the AMA RUC.

The survey is being conducted at the request of the RUC and stems from issues related to budget neutrality. As part of the RUC process, specialty societies must provide an estimated utilization for any new or revised family of codes. CMS productivity data dating back to 2014 identified concerns related to the use of the add-on codes that identify each additional joint treated. The possibility of incorrect coding of per nerve instead of per joint was discussed and a CPT Assistant article was published in February 2015. Changes were made to the 2016 CPT guidelines for this group of codes clarifying the correct reporting of the add-on codes. The RUC allowed time for these efforts to take effect and reviewed the utilization data again in October 2019. The Relativity Assessment Workgroup (RAW) of the RUC noted that the growth in these services is appropriate as patient population requiring these services has grown. However, due to the extensive growth and original incorrect assumptions about distribution of reporting, the Workgroup determined that a new survey is required.

If you receive a request to survey these codes, please remember your input in this survey is vital. The specialty societies ability to impact the work recommendations is dependent on robust and meaningful data. If you have any questions, please contact Emily Hill, AAPM Coding and Reimbursement Liaison, at: [email protected].

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American Academy of Pain Medicine